Transmission Roadmap 2010

8/6/2019 Transmission Roadmap 2010

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This report will be updated regularly to refect new in ormation.


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Western Governors AssociationRenewable Energy Transmission Roadmap

June 2010

Table of ContentsPre ace . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Overview o Renewable Energy Project Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Key Permitting Considerations in the Western U.S. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Keys or a Success ul Project . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Notes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12


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PrefaceThe Western Governors Association is an independent bipartisan association o 19 States and 3 U.S. Fla

Paci c Islands. Through their Association, Governors identi y and address key policy and governance issuesin natural resources, the environment, human services, economic development, international relations andpublic management.

Governors select issues or review based on regional interest and impact. The WGA helps the Governor

develop strategies both or complex long-term interests acing the West, and or the regions immediateneeds. Governors use WGA to develop and advocate policies that refect regional interests and relationshipsin debates at the national and state levels. The WGA also acts as a center o innovation to nd promisingsolutions or problems in the region. The WGA has been involved in energy policy issues1 through resolu-tions, initiatives, studies and reports, and through the activities o the Western Interstate Energy Board2,which serves as the energy arm o the WGA.

In December o 2009, the United States Department o Energy awarded the WGA $12 million in grantsunded rom the American Recovery and Investment Act o 2009, to assist 11 states in the Western Interco

nection in planning or new electric transmission in rastructure considering uture demand, diversity o resources, environmental concerns and energy e ciency3.

On December 2, 2009, Governor Brian Schweitzer stated the ollowing in a letter4 to Robert Kondziolka,

then Manager o Transmission Planning at Salt River Project and Chairman o the Southwest Area Transmission planning group:

One o the most rustrating issues that developers can ace is the daunting process o understanding hoacilitate and expedite transmission siting and permitting. By providing even this basic in ormation, especiall

small and medium developers, we can bridge the disconnect between project conception and delivery o critic power to load centers. The WGA staf has in ormed me that you have graciously volunteered to put together abasic interstate roadmap that will help developers navigate siting and permitting.

Rob Kondziolka o Salt River Project and Greg Bernosky o Arizona Public Service provided valuableguidance in the preparation o the Roadmap. We would also like to thank the engineering and consulting

rm o K.R. Saline & Associates, PLC or their assistance in preparing this document.

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IntroductionRenewable energy is becoming an increasingly large part o state energy port olios in the West. However,

the continued expansion o renewable energy is primarily dependent on the availability o transmission.Development o a renewable energy project in the Western United States is ormidable and requires

interested parties to navigate a path o complex ederal, state and local regulatory approvals and permits.Encircling this process is the electric utility industry and the variety o studies, technical modeling processes,

economic assessments and operational requirements that o ten drive the development o electric in rastructure.To assist in navigating the renewable energy development process, the Western Governors Association

has prepared this roadmap o the steps an energy project, be it generation or transmission, typically takesrom concept to construction. The document highlights key in ormation compiled rom existing national,

regional, and state studies, and directs the reader to sources o in ormation that contain additional details. Itidenti es key issues that typically ace energy development projects in the Western U.S. and some strategies

or addressing challenges that may arise along the way. The overall objective is to assist energy projects asthey get underway by providing an outline o development activities, including process, timing, potentialhurdles and key stakeholders.

No document could cover all o the processes or issues that might arise in each state within the WGAootprint. For that reason, energy project developers are encouraged to identi y and work with local agencies

and stakeholders in their speci c geographical area, con er with organizations that support the developmento energy projects, and engage pro essionals in relevant disciplines in order to maximize the potential

or project success.

Organization of the RoadmapThis document is organized in three sections:

Overview o Renewable Energy Project Development Key Permitting Considerations in the Western U.S. Keys or a Success ul Project

These sections are supplemented by concluding remarks and links to an online glossary o requently

used electric industry terms and relevant supporting appendices.


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Overview of Renewable EnergyProject Development

The need or adequate, reliable, economical, and diverse energy in rastructure to supply electricenergy or residential, commercial and national security purposes is unquestioned5. While ederal and stateincentives, such as tax credits and renewable port olio standards, have encouraged development o theseprojects, completing renewable energy projects remains extremely complex. The projects are highly capitalintensive and require integration with existing energy in rastructure, natural resources and the humanenvironment.

Issues Facing Project Developers in the West 6

Although project permitting and transmissioninterconnection might be seen as separate processes to anovice developer, they are closely interrelated. The identi-

cation and de nition o a proposed renewable energyproject is an iterative one involving the interrelationshipsbetween nancial considerations, such as costs o permit-

ting and needed in rastructure, as well as the period o time that will be required to complete the process.

Selling Power to UtilitiesThe production and sale o electric energy is regulated

by state and ederal authorities. The Federal EnergyRegulatory Commission (FERC) regulates the wholesalesale o electric energy in interstate commerce7. Thisregulation may apply even though energy is generatedand sold in the same state8. Because o the specialized

knowledge and experience needed to navigate the FERCregulatory scheme9, renewable generation developers areencouraged to con er with competent advisors to assessthe need to obtain FERC authorization in order to sellelectric energy to wholesale purchasers. The process o obtaining FERC approval can be relatively simple, or morecomplex, depending upon the status o the applicant andits ability to exercise market power. Market power re ersto the ability o an entity to control or alter the price o electric energy because o its large capacity.

A generation developer may sell electric energy to a

utility either through a power purchase agreement (PPA)or on the open market. A PPA re ers to a contract between a generator and a utility or the sale o electricenergy. Utilities may issue Request or Proposals (RFP) in accordance with integrated resource plans.10 Atypical RFP (and resultant PPA) includes the amount o electric energy required (MWh), technology/resourccategories sought, term o the contract, commercial operation date, delivery point(s), transmission serviceoptions11, maximum bid price, handling o renewable energy credits, and criteria used or evaluation.

When deciding rom which generators to purchase energy, some utilities are required to use projecteasibility or viability evaluation criteria established by governmental regulations; others will use internally

developed standards.

4

Renewable energy projects can bea ected by a number o very di cultissues, including: Transmission capacity is limited, and

renewable resources can be, and o ten

are, remote rom urban load centers orexisting transmission in rastructure.

Developers requently encounterpublic opposition to their projects,based upon perceived aesthetic andeconomic impact o the in rastructurethat is necessary to generate andtransmit renewable energy.

The Western U.S. is host to largeamounts o public land, requiring eval-uation o environmental impacts by

multiple Federal agencies. State and local government, environ-

mental, land use and regulatoryapprovals are required on non- ederallands.

Requirements imposed by variousagencies and units o governmentare potentially in confict with oneanother.

Regulatory processes can lack coordi-nation and synchronization.


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TransmissionInterconnection Basics

An interconnection to a transmission systemis required in order to transmit the energyproduced to the utility purchasing the power.An interconnection provides the right to inject

power, but does not convey any rights to trans-mit the power. Transmission service is requiredin order to transmit the power, and there is aseparate process to acquire transmission service.The interconnection process is the proceduralpath a generation developer must ollow priorto transmission interconnection approval. Theinterconnection process is initiated when thegeneration developer submits an Application

or Interconnection (with the required depositand proo o site control) to the transmission

owner. The application is submitted a ter thepower producer has conducted a preliminaryassessment o project easibility.

The application study process is ormalizedwhen the Application or Interconnection is

approved by the transmission owner, typically within 10 days o receipt o the application. A series o up tothree technical studies is required to establish system reliability, system upgrade requirements, and toallocate costs. A typical technical study process or interconnection is illustrated inFigure 1below.

Figure 1 - Overview o Typical Technical Study Work Process

The interconnection process establishes technical viability o a generation project, and de nes the costsor the equipment and network upgrades necessary to allow or injection o the proposed resource by the

generator, in a manner that will not impact the reliability o the grid. It also allocates the costs or theneeded acilities.

Many utilities and transmission operators establish interconnection procedures that are modeled onFERC standardized ( pro orma) procedures. In general, an interconnection request must identi y the type o interconnection service requested (network or energy only), describe the location, output and equipment o the acility, provide detailed technical in ormation, include a cash deposit, and establish control o the projectsite. A ter the request, the generator must agree to pay or a series o technical studies. Additional depositswill be required or phases o these studies. The nal study (the acilities study) will estimate the costs o theupgrades, the schedule to per orm the upgrades, and equipment necessary or the interconnection.Subsequent agreements will address construction and operating responsibilities. An explanation o theboxes inFigure 1is included in Appendix F.

Transmission providers evaluate interconnection requests based upon a queue o requestors, with

Typical evaluation criteria might include theollowing, with each criterion receiving a di erent

weight depending upon the utility: Price. Developer experience: Ability to nance

prior projects; creditworthiness; engineering,

procurement and construction experience;ownership and operation o other acilities. Technology assessment: Complexity o design;

maturity; reliability; e ciency; availability;costs; comparison to technology in development;ease o construction.

Transmission elements: Scope o work orinterconnection acilities and upgrades; antici-pated length o time or studies, procuremento necessary equipment, engineering andconstruction.

Site control: Options to purchase; leases;ownership. Permitting: Complexity; sequence; likelihood

o success; anticipated completion date.

InterconnectionRequest Deposit varieswidely

Accepted - 10business days

FeasibilityStudy Costs vary 45 days tocomplete

System ImpactStudy Cost vary 60 days to

complete

InterconnectionAgreement Construction can

begin

Facilities Study Cost vary 90 days tocomplete


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requests reviewed in the order received. FERC requires standardized interconnection procedures or small(20 MW and under) and large (greater than 20 MW) generators. The queues12 identi y the date o the re-quest, electrical output, general location, interconnection point, requested in-service date, type o intercon-nection service, the status o the request, and the technical studies that are available. The identity o therequestor is not disclosed.

Generic Schedule for a Major Electric Transmission Project

Figure 2 Generic Schedule or a Major Transmission Project

Identification of MarketOne o the key decisions to be made by a renewable developer is identi ying the market or markets o

greatest interest. This decision will drive many o the signi cant processes that ollow. The most geographically proximate transmission line to the proposed project site might be unsuitable or the transmission o theenergy to the desired market or many reasons, including: lack o available transmission capacity, inappropriate voltage levels or the project size, or uneconomic costs o transmitting the energy to the purchaser over multiple transmission systems due to

additional wheeling costs (the cost paid to the owner o the transmission line) as a result o pancakedrates (multiple surcharges on transmission rates crossing several service territories).13

6

Notes

1. This provides a general timeline. This timeline o activities can be generally applied to projects 30 to 150 miles in length, involvesmore than 3 local jurisdictions, 2 to 3 ederal agencies, 1 to 3 state agencies, and more than 30 land owners. The planning process isa key uncertainty.

2. This timeline assumes a certi cate o public convenience and necessity (CPCN) is needed.

3. Issue Identi cation: The transmission project may be needed or reliability, economic reasons, and/or or renewable resources.

4. Planning Approval: Please see CAISO generator interconnection process and Order 890 planning process.

5. Pre-CPCN Activities include (a) project scope de nition, (b) project study area de nition, (c) environmental in ormation identi catioand compilation, (d) in ormational exchange with community leaders, (e) consultation with land use and natural resource manage-ment stakeholders, ( ) preparation o Proponents Environmental Assessment, and (g) preparation and ling o permit application.

6. CPCN Process: Please see CPUC timeline. Actual schedule depends on, among other things, (a) environmental setting and potential

impacts, (b) project complexity, and (c) level o public interest.7. Post-CPCN activities include right-o -way acquisition and resource agency permits acquisition. Additional time will be needed i

eminent domain action is necessary.


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Key Permitting Considerations in the Western U.S.The Federal government owns almost 30 percent o the land in the United States, and an even greater

percentage in the West.14 The ve states with the largest acreages o ederally owned land15 are Cali ornia,Arizona, New Mexico, Utah and Nevada16. Federal land ownership in the WGA region is signi cant, and thusdevelopment o renewable projects and in rastructure has the potential to include required land use author-izations (i.e. leases and rights o way) rom ederal agencies.

In addition to ederal lands, tribal lands also comprise a signi cant portion o land in the west. Develop-ment o projects on tribal lands will require tribal authorizations and in some cases ederal authorizations aswell. Many o the states in the West control School or Trust Lands that were designated as such byCongress in establishing territories and states. Such lands are held in trust by the states or the bene t o identi ed bene ciaries such as schools, universities or other public institutions. Because o the extent o these holdings in the West, the development o renewable energy projects and in rastructure may requirestate land use authorizations as well.17

Major Federal Environmental Laws Affecting Developers National Environmental Policy Act (NEPA)18 - Federal agencies are required to examine the environmental

consequences o signi cant ederal actions, such as grants o rights o way; conduct scoping to determinethe nature and extent o the study; disclose environmental impacts; consider alternatives to the requestedaction; and identi y mitigation measures19. Federal agencies issue regulations, handbooks20 and guidance21

regarding each agencys approach to NEPA compliance. Endangered Species Act 22 (ESA)- The purpose o this law is to protect threatened and endangered

species. The Fish and Wildli e Service (FWS) issues lists o species that are endangered (the species is indanger o extinction through all or a signi cant portion o its range), threatened (the species is likely tobecome endangered within the oreseeable uture), or are classi ed as candidate species (species orwhich the FWS has enough in ormation to propose listing, but is precluded rom doing so by higher listingpriorities). Section 7 o the ESA requires ederal agencies to consult with the FWS, which can issue a biolog-ical opinion or concurrence letter to the ederal agency regarding that agencys proposed action.23

Section 9 o the ESA prohibits the take o a threatened or endangered species. Take is de ned broadlyand includes actions that may harm a listed species, its habitat, or impair essential behavioral patterns.Section 10 o the ESA provides or the issuance o permits or the incidental take o a threatened orendangered species. In a situation where a Section 7 consultation is not required, a developer may needto obtain an Incidental Take Permit under Section 10 o the ESA.

National Historic Preservation Act24 - The purpose o this law is or the ederal government to provideleadership, contribute to, and encourage preservation o historic and prehistoric resources. Section 106 o the Act requires ederal agencies to consider the e ects o actions on historic properties and to provide orconsultation with the Advisory Council on Historic Preservation (or its designees)25. A State Historic Preser-vation O ce (SHPO) is the typical designee. This is known as a Section 106 consultation.

Clean Water Act (CWA)26 (Sections 401, 402 and 404) - The Clean Water Act regulates the discharge o

pollutants into waters o the United States27. Section 402 created the National Pollutant Discharge Elimina-tion System (NPDES) permit program that regulates point source discharges such as storm water. Section404 o the CWA Regulates dredge and ll activities and is jointly regulated28 by the United States Environ-mental Protection Agency (EPA) and the U. S. Army Corps o Engineers29. Section 401 o the CWA requiresstates to issue water quality certi cations prior to the issuance o a ederal 402 or 404 permit.

Clean Air Act30 - The purpose o this law is to protect and improve air quality. The EPA (or state or countyDEQs i so authorized) will require permits or certain emissions associated with any development activities,including construction activities such as diesel generators, as well as dust dispersal.

Federal Land Policy and Management Act of 1976 31- The purpose o this law is to establish public landpolicy and to establish guidelines or its administration to provide or the management, protection,


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Local Agency or Jurisdiction Permits Rezoning o the project site or special use permit Site plan approvals Drainage plan and construction plan approvals (dust control plans) Building permits and inspections Fire control and suppression plan approvals and hazardous materials storage and control plans Tra c impact studies (permits or access to local roadways and state highways) Plan approvals and permits or water supply systems and waste water systems Business licenses

Environmental NEPA study and Record o Decision (ROD) by ederal agency granting lease or rights o way and required

mitigation measures (amendment o existing land management plans) Endangered Species Act review/study Section 402 Clean Water Act (NPDES) discharge permit/pollution prevention plan Section 404 Clean Water Act discharge permit/study Cultural resources/archaeological studies/consultation with a with state historic preservation o ce and/or

Native American tribe or nation Noise emissions/inter erence with communication signals study Air emissions permit or construction activities (including dust emissions) and generators ( ederal, state or

local DEQ) Water supply veri cations and approvals or water use Flood control approvals Consultations with state departments or game and sh or natural resources - amendment o existing

land management plans

Regulatory Approvals Which May Require Environmental Information, Studiesand Analysis

Authorizations rom state siting authorities regarding the environmental compatibility o the project andapproving its speci c location acilities allowed, and required mitigation measures State land department leases or rights o way (precursor environmental studies and survey in ormation

vary rom state to state) Approval by public utility commission or other body regarding the need or the project or a certi cate o

convenience and necessity

Projects Using Federal LandsA project which requires ederal action will39 trigger NEPA compliance. The NEPA process may require

public scoping, which will provide stakeholders, including agencies, individuals, and organizations, theopportunity to comment. These comments will be used to identi y the scope and content o the required

NEPA document. It is not uncommon or a NEPA study to include a plan o development or construction,operations, maintenance, and access to the project acilities.

Depending upon the issues identi ed, the studies required could take up to a year or longer to complete.Iterative dra ts o the NEPA document will be circulated or months among cooperating agencies be ore a

nal dra t is issued or public comment. These comments are then reviewed and addressed in the naldocument. The compilation o the public comments and assessment process will require additional months.

A ter the nal NEPA document is issued, the developer will complete the application process or the ederal action desired (such as granting a right-o -way), will identi y the mitigation measures required, andestablish a project schedule or the implementation o the mitigation measures. The ederal action applica-tion process and mitigation scheduling can require a ew more months. Approval o the ederal application


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allows the energy producer to begin project construction.There are ederal permits that could be required in addition to NEPA compliance, including water

discharge and air permits. Some o these ederal permits could require public notice and outreach to stake-holders, technical studies, and review by sta . These processes can take up to a year or more and might bepursued contemporaneously with any required NEPA studies.

Projects Using State Land

I the project site will require leases or rights-o -way on state land, the developer may be required toprovide or pay or studies to assess the environmental and economic impacts o the proposed use on thestate land. The developer may be required to identi y a legally described and surveyed location. The devel-oper must synchronize the identi cation o a speci c route with the state siting process to ensure thespeci c route and land identi ed has been authorized or use by the state siting authorities.

Biological, cultural resource and appraisal reports may be required be ore the application or land use isdeemed complete. Some o these reports might be based upon studies per ormed in connection with NEPAstudies. Ordering and completing the survey and legal descriptions and studies could take 12 to18 monthsor longer. Agency review and nal approval o the application and studies will require additional time, and

ormal acquisition processes or auction o the requested land could be held only periodically, which wouldrequire additional time.

State Siting ProcessesState siting processes vary greatly, depending upon the jurisdiction. A developer should identi y the

environmental studies, community outreach, and other in ormation that will be required or these processesand compare them to what will be required by NEPA processes in order to analyze potential e ciencies andopportunities or synchronization.

Development Process

10

ResourceTechnologySelection

AcquireLand

Transmission IdentifyRequiredPermits

PerformStudiesNeeded

forPermits

SubmitPermitApps.

Obtain

CCNfromPUC

All PermitsApproved

Design/ ConstructProject

SitingAnalysis:Dene

Study Area/ Public

Outreach

Federal NEPA CAA

CWA Fish and Wildlife Others

State Cert. of Convenience

and Necessity Water Supply

State Game and Fish State DEQ State Historic

Preservation

Local Land Use/ Zoning Drainage/

Construction Plans Building Permits Traffic Studies Fire Control


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Keys for a Successful ProjectThe complexity o permitting and licensing processes and the need or coordination, synchronicity,

and e ciency has been the subject o Congressional review,40 and study,41 and ederal agency42 attention.Bills have been introduced at ederal and state levels; workshops have been convened by state public utilitycommissions, utilities, environmental groups and industry organizations; and policy papers and legalarticles have been published, all on the topic o streamlining processes that are inherently complicated by

the interactions among multiple entities with jurisdiction over components o the overall developmentprocess.

Well planned projectscan achieve licensing and permitting on schedule and on budget. Projectplanning is essential. This will include atal-faw and critical-path analyses which should be prepared at theoutset, and updated regularly. Success o a project relies on coordinated e orts by various entities that mustreview projects and assess impacts. An early identi cation o which agencies are involved, what theirrequirements are, what actions must precede other actions and estimates o time lines or these actionsbased upon investigations o similar projects will minimize rustration and expense. Environmental andengineering consultants can provide a developer with a project schedule, consisting o a permit list thatis project-speci c and includes consideration o developer-provided milestones or completion o certaintasks or the issuance o necessary permits.

Key Steps: Communicate, Communicate, Communicate A developer should have preliminary meetings with key regulatory agencies to identi y permits required

and to provide in ormation regarding the project. Project developers should be involved in regional planning processes that provide an evaluation o the

project by utilities, transmission owners, environmental agencies, and regulators. Such preliminary reviewsgreatly acilitate project easibility analyses.

Developers should engage in preliminary dialogues with the environmental community early during theproject planning process, be ore the start o any ormal study process. This will provide a developer withimportant in ormation regarding potential environmental problems that could be eliminated by modi ca-tions to the project scope or location. Avoidance o environmental issues can be more time and coste ective than identi ying and then implementing mitigation measures. Alternative route options providea way to avoid sensitive biological and cultural resource issues and can be considered a primary environ-mental mitigation measure. Developers should be willing to make changes to the project plan when it isreasonable and easible to do so. I mitigation measures are proposed it may be necessary to establishmethods to evaluate their e ectiveness.

An early public/stakeholder/community/landowner outreach process will also provide the developer within ormation regarding key issues o concern, which may not be sel evident or obvious, but are nonethelesspower ul drivers o the content and timing o environmental permitting and licensing processes. E ectivecomponents o this outreach process could include Web sites, newsletters, open houses, communityleader orums, and a system or tracking comments. Early outreach and identi cation o communityconcerns may avoid costly delays due to community opposition.

ConclusionObtaining permits or renewable energy and transmission can be a complex and time consuming

process. There are a myriad o ederal, state and local requirements to navigate. While this document couldnot possibly cover every situation in every state or county, it provides those considering projects with areasonably comprehensive view o the steps and possible organizations involved.


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Notes1 See Energy and Transmission Initiative web link at:http://www.westgov.org/index.php?option=com_content&view=article&id=129&Itemid=57

2 See WIEB at: http://www.westgov.org/wieb/

3 Detailed in ormation regarding the award at:http://www.westgov.org/index.php?option=com_content&view=article&id=129&Itemid=57

4 http://www.westconnect.com/ lestorage/Transmission%20Roadmap%20request.pd

5There is broad agreement that the Western U.S. must act now to ensure it will have a diverse supply o secure, environmentally responsible and a ordable energy well in the uture. By acting now, we will be able to continue our economicprogress, protect our outstanding quality o li e and harness our abundant domestic energy resources. Clean andDiversi ed Energy Committee Report to the Western Governors June 2006http://www.westgov.org/index.php?option=com_content&view=article&id=129&Itemid=57

6 Holtkamp, James A. and Davidson, Mark A. Transmission Siting in the Western United States: Overview and Recommedations Prepared as In ormation or Western Interstate Energy Board. Holland & Hart, August 2009.

7 16 USC 824-824m

8 This is because o the physics o electricity. Any electricity which enters the grid immediately energizes the entire grid(the Western Interconnection) which is an interstate network.

9 For example, public power entities may not be regulated by FERC or some purposes. This roadmap assumes a utilitywhich is regulated by FERC.

10 Speaking very generally, an integrated resource plan is an evaluation o the: anticipated electrical load demand;applicable rules and regulations; technical requirements; nancial considerations; and generation technologies and anidenti cation o goals and objectives or the acquisition o the necessary electricity.

11 In FERC Order 2004 FERC required that regulated utilities must operate their transmission unctions independent romarket unctions and prohibits passing o in ormation between the two unctions. See

http://www. erc.gov/en orcement/stand-conduct.asp and orders cited therein.

12 The appendix contains links to websites which contain the transmission providers queues.

13A developer must not only pay or the costs o network upgrades and the in rastructure needed to connect the projectto the grid, he must also pay or the transmission o the energy. The developer must not only request interconnection

with a transmission provider he must also request transmission service, which is a separate process. The cost o transmission service will vary, depending up the nature o the service provided; long term rm, short term rm and non rm. Inorder to deliver the electric energy to the purchaser, the use o two or more transmission systems may be necessary.Each transmission provider will charge, pursuant to its tari s (rates) or the transmission service necessary to wheel thpower across its system. This combination o charges is re erred to as pancaking. The utilities rates or tari s will typicbe posted on the utilities Open Access Transmission Tari (OATT) web page.

14 http://www.nationalatlas.gov/printable/ edlands.html

15 Excluding National Parks, National Forests, National Wildli e Re uges, Trust lands and lands withdrawn or militarypurposes. For a real property inventory o Dept o De ense lands see:http://www.acq.osd.mil/ie/download/bsr/BSR2009Baseline.pd

16 http://www.gsa.gov/graphics/ogp/FY_2008_Real_Property_Report.pd

17 Links to many State land Departments/ Boards/Commissions/Agencies and their permitting procedure are inAppendix B.

18 Text at Council o Environmental Quality website at http://ceq.hss.doe.gov/nepa/regs/nepa/nepaeqia.htm

19 For overviews o NEPA see: http://ceq.hss.doe.gov/nepa/regs/nepa/nepaeqia.htm and NEPA net page at:http://ceq.hss.doe.gov/nepa/nepanet.htm

20 NEPA Handbook June 2008. Bureau o Land Management:http://www.blm.gov/pgdata/etc/medialib/blm/wo/In ormation_Resources_Management/policy/blm_handbook.Par.84688.File.dat/h1790-1-2008.pd NEPA Handbook USFWS: http://www. ws.gov/r9esnepa/TOCnotebook.pd and

12


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21 NEPA Procedures and Guidance. USFS.: http://www. s. ed.us/emc/nepa/nepa_procedures/index.htm

22 US FWS ESA page: http://www. ws.gov/endangered/whatwedo.html

23 ESA Basics US FWS: http://www. ws.gov/endangered/ actsheets/ESA_basics.pd

24 Text o law at: http://www.achp.gov/nhpa.html Advisory Council on Historic Preservation:http://www.achp.gov/nhpp.html ( contains links to state ( http://www.ncshpo.org/ nd/index.htm ) and tribal( http://www.nps.gov/history/hps/tribal/thpo.htm ) preservation o cers)

25 http://www.achp.gov/docs/Section106FactSheet.pd

26 US EPA Clean Water Act page: http://www.epa.gov/lawsregs/laws/cwa.html

27Waters o the United States is a term which is de ned in statute and urther re ned by United States Supreme CourtOpinion .For a detailed analysis see: http://www.epa.gov/wetlands/guidance/CWAwaters.html

28 Summaries o Section 404 program at http://www.epa.gov/owow/wetlands/pd /reg_authority.pd

29 US Army Corps o Engineers: http://www.usace.army.mil/about/Pages/Home.aspx

30 US EPA web page or Clean Air Act: http://www.epa.gov/air/caa/

31 43 USC Chapter 35 http:// rwebgate.access.gpo.gov/cgi-bin/usc.cgi?ACTION=BROWSE&TITLE=43USCC35&PDFS=YES

32 16 U.S.C 703- 712

33Department o De ense Environment, Sa ety and Occupational Health Network and In ormation Exchangehttps://www.denix.osd.mil/portal/page/portal/denix

34 May 20, 2010 Testimony o Dr. Dorothy Robyn Deputy Under Secretary o De ensehttp://energy.senate.gov/public/_ les/Robyntestimony052010.pd

35 http://www. aa.gov/

36 Code o Federal Regulations Title 14 Part 77 Objects A ecting Navigable Air Space.

37 CEC-700-2009-015-SD

38 http://www.energy.ca.gov/2009publications/CEC-700-2009-015/CEC-700-2009-015-SD.PDF

39 Federal agency implementing regulations may de ne categories o projects which will require speci c environmentalstudies and which will be categorically exempt. DOE: http://nepa.energy.gov/DOE_NEPA_documents.htm

40 The House Subcommittee on Energy and Mineral Resources and the House Subcommittee on Water and Power held a joint oversight hearing November 5, 2009 on Getting Past Gridlock: Models or Renewable Energy Siting and Transmission.Use ul presentation materials relevant to this topic rom the Bureau o Land Management, regulators, environmentalgroups, utilities, business groups and WGA o cers, are posted at:http://resourcescommittee.house.gov/index.php?option=com_jcalpro&Itemid=27&extmode=view&extid=304

41 Luther, Linda. The National Environmental Policy Act: Streamlining NEPA. Congressional Research Service, Report No.RL 33267, December 2007 : http://assets.opencrs.com/rpts/RL33267_20071206.pd

42 In October, 2009 Nine ederal agencies established a MOU regarding coordination in ederal agency review o electrictransmission acilities on ederal land or projects o high voltage transmission lines which cross jurisdictions administeredby more than one ederal agency. See:http://www.whitehouse.gov/ les/documents/ceq/Transmission%20Siting%20on%20Federal%20Lands%20MOU.pd


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Transmission Roadmap 2010

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